Compliance Blog

The Compliance Guy is headed out of town for his honeymoon.  I plan on avoiding bear attacks in Wyoming and Colorado for the next 10 days or so.  With that in mind, I thought I'd share a bit of a column I penned a while ago. 

• If you understand this sentence: Please contact NAFCU to see if they have the CFR, LCU, LOL or the FFIEC BSA/AML Manual that shows what NCUA expects an FCU to include in their CIP...you might be a compliance officer. One of these days, we have to run out of useful acronyms.  We just have to. 

• If you feel anxious when NCUA’s website is down...you might be a compliance officer.  I clearly remember my first email address. I was a sophomore at Penn State in 1993.  If someone told me that this “internet thing” would someday comprise the most useful work-related tool in my life, I would have laughed him out of the room.  This also explains why I do not dabble in stocks.

• If you browsed through an issue of Federal Register, a NAFCU Regulatory Alert, or an NCUA proposed rule while at the beach...you might be a compliance officer.  With the complexity and scope of compliance issues, it is hard to turn off the switch at times. Show me a good compliance officer, and I’ll show you someone who reads. A lot.

• If reading an NCUA legal opinion letter caused you to cheer or boo in your office (while alone)... you might be a compliance officer.  It is amazing how a three-page letter can make (or ruin) one’s day, isn’t it?

• If you ever worked on 15 different projects during the same day...you might be a compliance officer.  While I appreciate the challenge of new research projects, I also appreciate proper spacing between them.

• If you ever judge the performance of a regulatory agency by how well they organize the regulations and guidance section of their website... you might be a compliance officer.  Back in 1999, I almost cried when OSHA redesigned their web page.  When NCUA added the Google-driven search engine, I almost shed tears of joy.  This is what my life has become.

• If you lost track of time while reading an interesting article on the Bank Secrecy Act...you might be a compliance officer.  Yes, such things exist.

• If you managed to irk an entire marketing division within 15 minutes... you might be a compliance officer.  Compliance officers sometimes have to say no.  And when people call them at the last minute for advice and research, they sometimes say no at the last minute. 

• If you know the internet address of more than 10 regulatory agencies by memory... you might be a compliance officer.  When Al Gore invented the internet, I don’t think he realized how much he was helping compliance officers. 

• If you know what subject NCUA Letter to Credit Unions 124 addresses... you might be a compliance officer.  (It addresses real estate lending.  As if I needed to tell you guys that.)  I like to quote random citations like this at cocktail parties.  Did I mention that I’m single? Editor's note: my wife used to work on regs for Ag.  It takes one to know one.

• If you schedule vacations around NCUA examinations... you might be a compliance officer.  We do this, because we want to have vacations next year as well.

• Conversely, if BSA means the “Boy Scouts of America” in your mind... you probably are not a compliance officer.  Ignorance is bliss.  Indeed.

• If you get angry when a regulatory agency reorganizes the regulation section on its website... you might be a compliance officer.  See above.  Oh what the heck, this is worth another rant.  If it isn’t broke people, please do not fix it!  The FTC recently reorganized its web page.  It now takes me 20 minutes to find the FCRA on its site.  And as for the IRS webpage?  Grrrr.

• If your favorite online forum discusses the intricacies of the definition of a finance charge... you might be a compliance officer.  I wonder if the Federal Reserve knows how many times “is this a finance charge?” is uttered across America’s financial institutions each year.  My over-under is about a million.  Not that anyone would bet on that.  

• If text messaging occurs naturally to you due to your historic use of compliance-related acronyms...you might be a compliance officer.  This might be a stretch. My nephew used an acronym recently that left me completely baffled.  After 10 minutes of explanation from Adam, I was completely and utterly baffled. 

• If listening to Barry Manilow’s “Copa Cabana” makes you think of COPPA - the Children’s Online Privacy Protection Act (COPPA)... you might be a compliance officer.  I almost didn’t include this for two reasons.  First, now I can’t get that song out of my head.  I’m guessing a few of you will have the same problem.  I sincerely apologize for that.  Second, I really fear that some of you will now have an uncontrollable urge to bone up on COPPA just to make sure that there have been no recent developments.  (There are none…that I am aware of.  Great.  Now I have an urge to bone up on COPPA.  Ugh.)

Have a great weekend everyone.! And be nice to Steve next for the next few weeks!